At the beginning of each new year, facilities are reviewing their chemical and hazardous material storage activities to determine if an annual “Tier 2” report will need to be submitted this year. These reports are due no later than March 1 each year.
The Emergency Planning & Community Right-to-Know Act (EPCRA) was enacted by Congress to help local communities protect public health, safety, and the environment from chemical hazards. EPCRA Section 311-312 addresses the on-site storage of hazardous chemicals and extremely hazardous Substances (EHS) at a site. EPCRA applies to any facility at which a hazardous chemical (i.e, any material that requires an Safety Data Sheet, SDS, under OHSA Hazard Communication Standard), or EHS is present in an amount exceeding a specified threshold. These facilities must submit SDSs or lists of SDSs to the State and Local Emergency Planning Committees and local fire department the first time a material exceeds its threshold and then an annual hazardous chemical inventory forms (also known as Tier I and II forms) for each year it contiguous to exceed the threshold. Hazardous chemicals used in routine agricultural operations and fertilizers held for resale by retailers are excluded from reporting under EPCRA 311/312.
Caltha LLP provides technical support to facilities across the US to prepare and submit first time reporting under EPCRA 311 and annual Tier 2 Reports under EPCRA 312. Because reports are typically generated on-line using the EPA CDX system, Caltha can prepare reports on behalf of clients. Our clients then review and submit the reports electronically.